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Professor Philip G. Schrag (Georgetown) has submitted comments on the proposed the new immigration court procedures in the Immigration Court Practice Manuel, specifically the requirement for advance filing of evidence and briefs for nondetained respondents of 30 days before an individual calendar hearing (and proposing a 10 day requirement).

Nancy Morawetz, NYU Immigrant Rights Clinic, also filed comments on the new EOIR rules1. In addition to covering the 30 day issue raised in Phil Schrag's comments, these comments address a number of other ways in which the rules undermine the statutory right to counsel and fail to provide adequate safeguards for pro se litigants. The comment further encourages EOIR to postpone implementation of the rules until there is a fair collaborative process for designing any national manual. Download comments_5.13.08 FINAL.pdf